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24 Ent. & Sports Law. 3 (2006-2007)
Pinned down Labor Law and Professional Wrestling - Part III: What the Future Holds for Professional Wrestling's Labor Relations

handle is hein.journals/entspl24 and id is 3 raw text is: Pinned Down Labor Law and Professional Wrestling
Part III: What the Future Holds for Professional Wrestling's Labor Relations
By Jamie Sharp
This is the third and final part of a series on labor law issues in pro wrestling - the crossroad of sport and entertainment.

o long as Vince McMahon and World Wrestling
Entertainment dominate the professional wrestling
industry, wrestlers will have a difficult time organiz-
ing as a unified labor group. Nonetheless, the need to
unionize and protect the livelihood of wrestlers is more
important now than ever.
Health problems affecting wrestlers
Over the past ten years, professional wrestling fans have
been accustomed to a higher impact style where acrobatic
moves and the use of foreign objects are quite common.!
While the style is very exciting, this new style has resulted in
more injuries that undoubtedly will affect this generation of
Wrestlers as they grow older.2 Although injuries have always
been commonplace in professional wrestling, the frequency
of career-threatening injuries has increased to unprecedented
levels.3 World Wrestling Entertainment, Inc. (WWE) has even
taken note of these problems as it has required that its
wrestlers tone down their styles so as to minimize injuries.4
Regardless of these changes, fans expect a more physical style
that requires wrestlers to sacrifice their bodies to entertain
these fans, and wrestlers continue to test their physical limits.'
Perhaps the most disturbing health problem facing
wrestlers is not that they are injured more frequently and
severely than ever before but the effect that the wear-and-tear
from this high-impact style will have on their bodies when
they retire. In recent years, many wrestlers from the 1980s
have either undergone or need hip and knee replacement
surgeries to improve their quality of life.' This trend is partic-
ularly disturbing because the wrestlers undergoing these
procedures wrestled a particularly low-impact style, especial-
ly when compared to today's standards. For example, the
legendary Hulk Hogan, who rarely left his feet when he
wrestled, has had his knee and hip replaced,7 yet he is only
51 years old. If a wrestler such as Hogan has these kinds of
health problems in his early fifties, then the wrestlers of the
current generation who wrestle a much more physically
demanding style should expect to live in pain once their
careers end.
Another disturbing health problem facing wrestlers is
the effect of steroids. Since the 1970s, wrestlers have been
linked to steroids.' Steroids allow wrestlers to add muscle
mass to enhance their appearance.10 To the fans, wrestlers
who are on steroids appear superhuman because they are
freakishly muscular. In the 1980s, Vince McMahon capital-
ized on this superhuman image by promoting these large
muscle-bound wrestlers.1 Unfortunately, while steroids
enhance a user's appearance, steroids also have debilitating
health effects.'2 When the health problems associated with
steroids became well-known-in the early 1990s, the
Department of Justice began an investigation of Vince
McMahon for steroid distribution.3 The investigation and

subsequent trial lasted several years but, in 1994, McMahon
was acquitted of steroid distribution.4
Nonetheless, the media coverage of former World
Wrestling Federation (WWF) wrestlers such as Hulk Hogan
and the Ultimate Warrior, who testified that they had used
steroids, tainted the industry. In an effort to distance itself
from the steroid problem, the WWE deemphasized muscle-
bound wrestlers in favor of smaller wrestlers such as Bret Hart
and Shawn Michaels5 The company also began testing its
wrestlers for anabolic steroids.6 As time progressed, the com-
pany eventually abandoned its steroid testing policy and
reverted to promoting muscle-bound wrestlers.'7 While the
company openly frowns upon steroid use, the increased pro-
motion of muscle-bound wrestlers sends a dangerous mes-
sage to smaller wrestlers: get big through whatever means
necessary or you will not be working for the WWE.'9 By pro-
moting muscle-bound wrestlers, the WWE implicitly encour-
ages the use of steroids by its wrestlers. Sadly, over a dozen of
the stars that worked for the company during its last era of
promoting muscle-bound wrestlers have suffered untimely
deaths before the age of 50.1 This strategy of promoting mus-
cle-bound wrestlers while not testing the wrestlers for steroids
is a recipe for disaster, especially when these muscle-bound
wrestlers wrestle such a high-impact style.
To illustrate the potential health problems associated with
today's style of professional wrestling and the use of
steroids, look at the life of The Dynamite Kid Tom
Billington. In the 1980s, Billington was arguably the world's
best wrestler and his innovative style was years ahead of its
time.21 Billington, however, was only 5 feet 8 inches tall in an
era where muscle-bound wrestlers received much of the
attention.2? Even though his talent was matched by few,
Billington was viewed as too small so he took steroids to add
muscle mass, which helped to further his career. Through-
out his career, Billington suffered from constant back pain
due to his high impact ring style.4 In order to cope with the
nagging pain, Billington took prescription drugs. Even-
tually, Billington's ignorance of the pain led to a freak, but
devastating, back injury.26 After taking several months off,
Billington returned to work, using his high impact style to
wow fans and steroids to enhance his physiqueY.2 Billington,
however, continued to wrestle in extreme pain until finally
retiring less than five years later? In the years following his
retirement,' Billington's health continued to fail and, by the
late 1990s, Billington was largely confined to a wheelchair
with little money and no career prospects.29
Today's wrestlers should concern themselves with the
plight of Tom Billington for three reasons. First, today's
wrestlers should be aware that Billington was one of the few
wrestlers from the previous generation that wrestled a style
similar to today's wrestlers and, undoubtedly, Billington's in-
ring style was a major factor in the health problems that

Spring 2006 /Volume 24, Number 1 / Entertainment and Sports Lawyer 3

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